NPDES Permit No. IL0078981
Notice No. BWC:14062701bwc.docx
Public Notice Beginning Date: November 6, 2014
Public Notice Ending Date: December 8, 2014
National Pollutant Discharge Elimination System (NPDES)
Permit Program
Draft New NPDES Permit to Discharge into Waters of the State
Public Notice/Fact Sheet Issued By:
Illinois Environmental Protection Agency
Bureau of Water,
Division of Water Pollution Control
Permit Section
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
217/782-0610
Name and Address of Discharger:
Name and Address of Facility:
Enbridge Pipeline, LLC
3399 East Grand River, Suite 100
Howell, Michigan 48843
Enbridge Pipeline, LLC
Manhattan Station
15637 West Bruns Road
Manhattan, Illinois 60442
(Will County)
The Illinois Environmental Protection Agency (IEPA) has made a tentative determination to issue a NPDES permit to discharge into the
waters of the state and has prepared a draft permit and associated fact sheet for the above named discharger. The Public Notice period
will begin and end on the dates indicated in the heading of this Public Notice/Fact Sheet. The last day comments will be received will be
on the Public Notice period ending date unless a commentor demonstrating the need for additional time requests an extension to this
comment period and the request is granted by the IEPA. Interested persons are invited to submit written comments on the draft permit to
the IEPA at the above address. Commentors shall provide his or her name and address and the nature of the issues proposed to be
raised and the evidence proposed to be presented with regards to those issues. Commentors may include a request for public hearing.
Persons submitting comments and/or requests for public hearing shall also send a copy of such comments or requests to the permit
applicant. The NPDES permit and notice number(s) must appear on each comment page.
The application, engineer's review notes including load limit calculations, Public Notice/Fact Sheet, draft permit, comments received, and
other documents are available for inspection and may be copied at the IEPA between 9:30 a.m. and 3:30 p.m. Monday through Friday
when scheduled by the interested person.
If written comments or requests indicate a significant degree of public interest in the draft permit, the permitting authority may, at its
discretion, hold a public hearing. Public notice will be given 45 days before any public hearing. Response to comments will be provided
when the final permit is issued. For further information, please call Brian W. Cox at 217/782-0610.
The applicant operates a refined petroleum pipeline (SIC 4612). Wastewater will be generated from the hydrostatic testing of one new
storage unit which has never contained any product and will generate a total of 21 million gallons of hydrostatic test water. Additionally,
a segment of a repaired pipeline which contained natural gas diluent will also be tested which will generate approximately 2 MGD of
hydrostatic test water. The hydrostatic test water will be discharged at an average rate of 4.9 MGD from Outfall 003.
Similar hydrostatic testing discharges were previously permitted for this facility under NPDES Permit Number IL0078981 which was
issued June 25, 2009 and terminated November 4, 2010.
Public Notice/Fact Sheet -- Page 2 -- NPDES Permit No. IL0078981
Application is made for the new discharge which is located in Will County, Illinois. The following information identifies the discharge point,
receiving stream and stream classifications:
Outfall
003
Receiving Stream
Prairie Creek
Latitude
41° 24’ 12"
Longitude
North
87° 59’ 28"
West
Stream
Classification
Stream Integrity
Rating
General Use
C
The stream segment, IL_FA-01, receiving the discharge from outfall(s) 003, is not on the 2014 303(d) list of impaired waters and is not
considered a biologically significant stream on the 2008 Illinois Department of Natural Resources Publication – Integrating Multiple Taxa
in a Biological Stream Rating System. The stream segment receiving the discharge from outfall 003 is also designated enhanced for
dissolved oxygen in Title 35 Ill. Adm. Code § 302, Appendix D.
To assist you further in identifying the location of the discharge please see the attached map.
Public Notice/Fact Sheet -- Page 3 -- NPDES Permit No. IL0078981
The discharge(s) from the facility shall be monitored and limited at all times as follows:
Outfalls: 003 Hydrostatic Test Water (DAF = 4.9 MGD)
LOAD LIMITS lbs/day
DAF (DMF)
PARAMETER
30 DAY
AVERAGE
DAILY
MAXIMUM
CONCENTRATION
LIMITS mg/l
REGULATION
30 DAY
AVERAGE
DAILY
MAXIMUM
REGULATION
Flow (MGD)
pH
35 IAC 302.204
Total Suspended Solids
15
30
35 IAC 304.124
Oil and Grease
15
30
35 IAC 304.124
Iron
2
4
35 IAC 304.124
0.05
35 IAC 302.208
Total Residual Chlorine
Dissolved Oxygen
35 IAC 302.206*
*During the period of March thru July, dissolved oxygen (DO) shall not be less than 5.0 mg/L at any time and 6.25 mg/L as a daily mean
averaged over 7 days. During the period of August thru February DO shall not be less than 4.0 mg/L at any time, 4.5 mg/L as a daily
mean averaged over 7 days and 6.0 mg/L as a daily mean averaged over 30 days.
The following explain the conditions of the proposed permit:
The special conditions clarify flow monitoring requirements, pH limitations, TRC limitations and monitoring requirements, monitoring
location requirements, discharge monitoring report (DMR) submission requirements, dissolved oxygen limitations, prohibition of offensive
conditions, soil erosion protection requirements, reopener conditions, and field office notification requirements.
Public Notice/Fact Sheet -- Page 4 -- NPDES Permit No. IL0078981
Antidegradation Assessment for Enbridge Pipelines – Manhattan Station
NPDES Permit No. IL0078981
Will County
The subject facility has applied for an NPDES permit for the discharge of hydrostatic test water. The hydrostatic test water will be
generated from the installation of one new storage tank which has never contained any product and from a repaired section of a pipeline
used to transport diluent (natural gas). The tank will generate a total of 21 million gallons of hydrostatic test water and the repaired
segment of the diluent pipeline will generate approximately 2 million gallons of hydrostatic test water. Prior to operation, the storage tank
and the repaired section of pipeline are hydrostatically tested for structural integrity to ensure that they will not leak. The source of the
water used to conduct these tests will be obtained from the Village of Manhattan’s municipal water supply. Prior to conducting the
hydrostatic test on the repaired segment of the diluent pipeline, the pipe will be thoroughly cleaned to remove any residual product. An
energy dissipating structure will be used at the outfall to prevent erosion. The hydrostatic test water will be discharged to Prairie Creek at
an average flow rate of 4.9 MGD. In the event that a failure of the test is discovered through the initial testing, follow-up tests will be
required after the leak is repaired. The requested appropriation and discharge amounts include these follow-up tests that may not be
required. Similar hydrostatic testing discharges were previously permitted for this facility under NPDES Permit Number IL0078981 which
was issued June 25, 2009 and terminated November 4, 2010. The antidegradation assessment was public noticed May 13, 2009 for the
hydrostatic testing associated with the permit issued June 25, 2009 and allowed the discharge of 1.2 MGD of hydrostatic test water to
Prairie Creek, in addition to other hydrostatic testing discharges.
Identification and Characterization of the Affected Water Body.
Segment FA-01 of Prairie Creek is a General Use water body with zero 7Q10 flow existing upstream. This stream segment is not listed
on the Agency’s 2014 Section 303(d) List of impaired water bodies. This section of the stream has been assessed as fully supporting
aquatic life uses. Prairie Creek is not listed as a biologically significant stream in the 2008 Illinois Department of Natural Resources
Publication Integrating Multiple Taxa in a Biological Stream Rating System, but is given an integrity rating of C at the location of the
hydrostatic test water discharge. Prairie Creek is designated as enhanced water pursuant to the dissolved oxygen water quality
standard.
Identification of Proposed Pollutant Load Increases or Potential Impacts on Uses.
The steel pipe and storage tanks may contain iron filings and cutting oil. The amount picked up in the hydrostatic test water will be
minimal. Any residual natural gasoline from the repaired segment of pipeline should be minimized by cleaning the pipeline prior to the
testing. It is not expected that any natural gasoline will be present in the hydrostatic discharge. No impacts on designated uses of the
water bodies are anticipated due to the nature of these materials and the small amounts present. The water source is municipal,
therefore chlorine may be present. However, dechlorination may be performed as necessary if measurable residuals are present in
discharged water.
Fate and Effect of Parameters Proposed for Increased Loading.
Iron will remain in the stream continuum unless it becomes part of the bed sediments. Iron is a common natural component of bed
sediments and the effect will be imperceptible. The oil will volatilize or be broken down by natural processes. Quantities involved are
small and oil will not be visible.
Purpose and Anticipated Benefits of the Proposed Activity.
Hydrostatic testing of pipelines is a public and environmental safety procedure.
Assessments of Alternatives for Less Increase in Loading or Minimal Environmental Degradation.
The US Department of Transportation requires that pipelines be hydrostatically tested before being placed in use. The discharges from
the hydrostatic tests will be temporary and intermittent.
Alternatives to the proposed discharge of the hydrostatic test water are not reasonable. The water could be hauled from the site by trucks
to a Publically Owned Treatment Works (POTW). This would not only be expensive, but is also wasteful of the treatment capacity and
function of the POTW in that very clean water would be passed through the plant. Likewise, no sanitary sewer line was in close proximity
to the proposed pipeline route such that the water could be transported to the POTW in that manner and again, a POTW would not want
clean water that would waste resources at the plant. Spray irrigation on farm fields was also rejected because testing would potentially
occur at any time of year and tests occurring outside of the irrigation window would have to be stored, which would be difficult in terms of
procuring equipment to store such a large quantity of water, given the temporary nature of the discharge.
Summary Comments of the Illinois Department of Natural Resources, Regional Planning Commissions, Zoning Boards or Other
Entities
The Illinois Department of Natural Resources was consulted regarding threatened and endangered species issues via the EcoCAT
system on October 01, 2013. The only protected resource identified was the Franklin’s Ground Squirrel (Spermophilus franklinii).
However, no aquatic endangered species were indicated from Prairie Creek. IDNR terminated consultation in a letter dated October 02,
2013.
Public Notice/Fact Sheet -- Page 5 -- NPDES Permit No. IL0078981
Agency Conclusion.
This preliminary assessment was conducted pursuant to the Illinois Pollution Control Board regulation for Antidegradation found at 35 Ill.
Adm. Code 302.105 (antidegradation standard) and was based on the information available to the Agency at the time the draft permit was
written. We tentatively find that the proposed activity will result in the attainment of water quality standards; that all existing uses of the
receiving stream will be maintained; that all technically and economically reasonable measures to avoid or minimize the extent of the
proposed increase in pollutant loading have been incorporated into the proposed activity; and that this activity will benefit the community
at large by providing for safety testing of a petroleum product pipeline. Comments received during the NPDES permit public notice period
will be evaluated before a final decision is made by the Agency.
NPDES Permit No. IL0078981
Illinois Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois
62794-9276
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
New (NPDES) Permit
Expiration Date:
Issue Date:
Effective Date:
Name and Address of Permittee:
Facility Name and Address:
Enbridge Pipeline, LLC
3399 East Grand River, Suite 100
Howell, Michigan 48843
Enbridge Pipeline, LLC
Manhattan Station
15637 West Bruns Road
Manhattan, Illinois 60442
(Will County)
Discharge Number and Name:
Receiving Waters:
003
Prairie Creek
Hydrostatic Test Water
In compliance with the provisions of the Illinois Environmental Protection Act, Title 35 of Ill. Adm. Code, Subtitle C and/or Subtitle D,
Chapter 1, and the Clean Water Act (CWA), the above-named permittee is hereby authorized to discharge at the above location to the
above-named receiving stream in accordance with the standard conditions and attachments herein.
Permittee is not authorized to discharge after the above expiration date. In order to receive authorization to discharge beyond the
expiration date, the permittee shall submit the proper application as required by the Illinois Environmental Protection Agency (IEPA) not
later than 180 days prior to the expiration date.
Alan Keller, P.E.
Manager, Permit Section
Division of Water Pollution Control
SAK:BWC:14062701bwc.docx
Page 2
NPDES Permit No. IL0078981
Effluent Limitations and Monitoring
1. From the effective date of this permit until the expiration date, the effluent of the following discharge(s) shall be monitored and limited
at all times as follows:
Outfalls: 003 Hydrostatic Test Water (DAF = 4.9 MGD)
LOAD LIMITS lbs/day
DAF (DMF)
PARAMETER
30 DAY
AVERAGE
DAILY
MAXIMUM
Flow (MGD)
See Special Condition 1
pH
See Special Condition 2
CONCENTRATION
LIMITS mg/l
30 DAY
AVERAGE
DAILY
MAXIMUM
Total Suspended Solids
15
30
Oil and Grease
15
30
Iron
2
4
Total Residual Chlorine*
Dissolved Oxygen
* See Special Condition 11.
0.05*
See Special Condition 12
SAMPLE
FREQUENCY
Daily When
Discharging
Daily When
Discharging
Daily When
Discharging
Daily When
Discharging
Daily When
Discharging
Daily When
Discharging
Daily When
Discharging
SAMPLE
TYPE
Measurement
Grab
Grab
Grab
Grab
Grab
Grab
Page 3
NPDES Permit No. IL0078981
Special Conditions
SPECIAL CONDITION 1. Flow shall be measured in units of Million Gallons per Day (MGD) and reported as a monthly average and a
daily maximum on the Discharge Monitoring Report. The monthly average shall consist of the summation of the daily flows divided by the
number of days the facility discharged during that month.
SPECIAL CONDITION 2. The pH shall be in the range 6.5 to 9.0. The monthly minimum and monthly maximum values shall be
reported on the DMR form.
SPECIAL CONDITION 3. Samples taken in compliance with the effluent monitoring requirements shall be taken at a point representative
of the discharge, but prior to entry into the receiving stream.
SPECIAL CONDITION 4. The Permittee shall record monitoring results on Discharge Monitoring Report (DMR) Forms using one such
form for each outfall each month.
In the event that an outfall does not discharge during a monthly reporting period, the DMR Form shall be submitted with no di scharge
indicated.
The Permittee may choose to submit electronic DMRs (NetDMRs) instead of mailing paper DMRs to the IEPA. More information,
including
registration
information
for
the
NetDMR
program,
can
be
obtained
on
the
IEPA
website,
http://www.epa.state.il.us/water/net-dmr/index.html.
The completed Discharge Monitoring Report forms shall be submitted to IEPA no later than the 15th day of the following month, unless
otherwise specified by the permitting authority.
Permittees not using eDMRs shall mail Discharge Monitoring Reports with an original signature to the IEPA at the following address:
Illinois Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
Attention: Compliance Assurance Section, Mail Code # 19
SPECIAL CONDITION 5. If an applicable effluent standard or limitation is promulgated under Sections 301(b)(2)(C) and (D), 304(b)(2),
and 307(a)(2) of the Clean Water Act and that effluent standard or limitation is more stringent than any effluent limitation in the permit or
controls a pollutant not limited in the NPDES Permit, the Agency shall revise or modify the permit in accordance with the more stringent
standard or prohibition and shall so notify the permittee.
SPECIAL CONDITION 6. The permittee shall provide telephone notification to the Des Plaines IEPA Regional Office, at 847/294-4000,
at least 24 hours prior to any hydrostatic pipeline testing which may result in a discharge.
SPECIAL CONDITION 7. No effluent shall contain settleable solids, floating debris, visible oil, grease, scum, or sludge solids. Color
(including color resulting from dyes or tracers in the hydrostatic test water), odor and turbidity must be reduced to below obvious levels.
SPECIAL CONDITION 8. The effluent, alone or in combination with other sources, shall not cause a violation of any applicable water
quality standard outlined in 35 Ill. Adm. Code 302.
SPECIAL CONDITION 9. Appropriate measures shall be taken to prevent water quality impacts resulting from soil erosion due to the
discharge. The discharge flow rate shall be controlled so as not to cause scouring or other damage to stream beds or banks.
SPECIAL CONDITION 10. Solid waste such as straw used for filtering or erosion control shall be disposed of in accordance with state
and federal law.
SPECIAL CONDITION 11. All samples for Total Residual Chlorine shall be analyzed by an applicable method contained in 40 CFR 136,
equivalent in accuracy to low-level amperometric titration. Any analytical variability of the method used shall be considered when
determining the accuracy and precision of the results obtained. For the purpose of this permit Total Residual Chlorine means those
substances which include combined and uncombined forms of both chlorine and bromine and which are expressed, by convention, as an
equivalent concentration of molecular chlorine.
The water quality standard for TRC (0.011 mg/l 30-day average and 0.019 mg/l daily max) is below the method detection level (0.05 mg/l)
as described in 40 CFR 136. Therefore, for the purpose of this permit, the method detection level will be utilized to determine compliance
with the permit limit for TRC. A measurement of <0.05 mg/l reported on the DMR shall not be considered a violation of the water quality
based effluent limit. This reporting threshold is being established to determine compliance and does not authorize the discharge of TRC
in excess of the water quality based effluent limit.
SPECIAL CONDITION 12. During the period of March thru July, dissolved oxygen (DO) shall not be less than 5.0 mg/L at any time and
Page 4
NPDES Permit No. IL0078981
Special Conditions
6.25 mg/L as a daily mean averaged over 7 days. During the period of August thru February DO shall not be less than 4.0 mg/L at any
time, 4.5 mg/L as a daily mean averaged over 7 days and 6.0 mg/L as a daily mean averaged over 30 days.
SPECIAL CONDITION 13. All tanks, pipelines and appurtenances must be thoroughly cleaned and free of product residuals prior to
hydrostatic testing activities. This requirement does not apply to newly constructed tanks or pipelines. Cleaning waters are not
authorized to be discharged by this permit and must be disposed of at a site and in a manner acceptable to the Agency.